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Federal Computer Week: www.fcw.com

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FBI to build data warehouse Investigative data mining part of broad initiative to fight terrorism BY William Matthews June 3, 2002

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The FBI has selected "investigative data warehousing" as a key technology to use in the war against terrorism. The technique uses data mining and analytical software to comb vast amounts of digital information to discover patterns and relationships that indicate criminal activity. The same technology is widely used in the commercial sector to track consumer activity and even predict consumer behavior. The FBI plans to build a data warehouse that receives information from multiple FBI databases, according to Mark Tanner, the agency's information resources manager. Eventually, the warehouse might receive data from other law enforcement and intelligence agencies.

RELATED LINKS Sidebar: "Carnivore bites off too much" "Guidelines open data. Web to FBI" [FCW.com, June 3, 2002] "FBI counting on IT vs. terrorism" [Federal Computer Week, May 20, 2002] "Data-sharing projects gain momentum" [Federal Computer Week, March 4, 2002]

Symantec.

Data mining and data warehousing are part of a much larger FBI plan to acquire and employ modern information technology to thwart future terrorist attacks. "New technologies are required to support new and different operational practices," FBI Director Robert Mueller said May 29, detailing a sweeping overhaul planned for the federal law enforcement bureau. By the end of the summer, the FBI hopes to hire 900 new agents, including computer scientists and other IT specialists. The bureau overhaul also includes:

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COMPLIANCEHEADQUARTERS

FinCEN and the Section 314(a) Information Sharing Process Sue Burt, Senior Attorney - Bankers Systems Inc. December 2002

Overview Recently, the federal regulators shed new light on the section 314(a) information sharing process and the FBI Control List. In a Joint Agency Notice dated November 26, 2002, the regulators announced the discontinuation of the Control List and unveiled a new process for handling information requests from the government. This new process has been established by FinCEN pursuant to Section 314(a) of the USA PATRIOT Act and will replace the Control List. This article will discuss the new section 314(a) information sharing process and will explain what your financial institution must do to comply.

History 101 In order to better understand where we are headed with respect to government list searches and information sharing, it is helpful to appreciate where we have been. October 2001: In response to the September 11, 2001, attacks, the FBI created a confidential document called the Control List. The List was compiled by various federal law enforcement agencies conducting investigations into terrorist activities and consisted of names and identifying data of individuals and entities that these agencies believed may be related to their investigation. In October of 2001, the FBI provided the Control List to all financial institution regulators. The regulators, in turn, forwarded the List to financial institutions under their supervision once the financial institution had "registered" with its respective regulator. Financial institutions were given until October 12, 2001, to provide their regulator with the name of a senior level person as the contact for the Control List, that person's title, telephone number, and e-mail address. Upon receipt of this registration information, the regulators e-mailed a copy of the Control List to the institution. October 26,2001: The USA PATRIOT Act is signed into law and is intended to thwart terrorist activity in the United States. Title III of the Act amends a number of sections under the Bank Secrecy Act and sets out new compliance requirements for financial institutions. July 23,2002: The Department of the Treasury and the federal financial regulators release proposed customer identification program rules. The proposed rules implement section 326 of the USA PATRIOT Act and are intended to protect the U.S. financial system from money laundering and terrorist financing. These regulations spell out the requirements for establishing a customer identification program. One element of a CIP is to compare names with government lists prior to account opening and report any matches.

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COMPLIANCEH EADQUARTERS

Section 326 Customer Identification Programs: The Final Word Ted Dreyer - Attorney, Bankers Systems, Inc. April 2003 Sign Up Now to Learn About the Final USA PATRIOT Act Section 326 Regulations! Reserve Your Seat Today....More

After months of speculation and anticipation, the U. S. Treasury Department issued final regulations implementing the Customer Identification Program (CIP) requirements of the USA PATRIOT Act on April 30, 2003. Financial institutions across the nation must comply with this new regulation by October 1, 2003. This article will discuss the final CIP regulations and address the specific requirements for your institution.

Overview The USA PATRIOT Act was enacted in October 2001 and contains a number of provisions requiring the financial services industry to take steps to assist in the war against terrorism. Title III of the Act directly impacts financial institutions and amends several sections of the Bank Secrecy Act. Section 326 of Title III requires financial institutions to create and implement what is referred to as a customer identification program or CIP. The goal of such a program is to establish a process whereby institutions verify the identity of each customer or member at the time an account is opened. Following the outline of the proposed regulations, the final CIP regs establish who the law applies to and set out the key components of a CIP. These components include, identification, verification, government list comparisons, adequate notice and record retention.

Coverage The proposed regulations covered situations where a customer is seeking to open an account. A "customer" included any person or business entity opening the account and any "signatory" on the account. "Account" included any ongoing banking relationship, including lending transactions, deposit accounts or asset accounts. One problem was that there was no definition for the term "signatory" and there was uncertainty as to whether parties such as guarantors or holders of powers of attorney were covered. ^ A second troublesome issue related to the definition of "customer." Under the proposed rule, a customer is anyone seeking to open an account and commenters speculated that it would apply to persons who were denied accounts for whatever reason, and require maintaining identification records on persons who ultimately did not hold accounts. A number of questions surfaced regarding how it would apply in the event that a beneficiary of account (e.g. a trust or an IRA) became an account owner on the death of the originally named account holder. For this reason, many letters suggested limiting the definition to those who actually opened accounts.

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